Privacy Policy

The Wine Group LLC wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect or you provide through our websites that link to this Privacy Policy (the “Sites”). By using our Services, you agree to this Privacy Policy.

Last Updated: September 21, 2020

Personal Information
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. Personal Information we may collect includes:

• Name
• Postal address (including billing and shipping addresses)
• Telephone number
• Email address
• Credit and debit card number and security code
• Account username and password
• Social media identifier
• Birth date

Use of Personal Information
We and our service providers may use Personal Information:

• To respond to your inquiries, fulfill your requests, fulfill your orders of our products.
• To send administrative information to you, such as changes to our terms, conditions, and policies, as well as marketing communications that we believe may be of interest.
• To personalize your experience with the Services by presenting products and offers tailored to you and to facilitate social sharing functionality.
• To allow you to participate in sweepstakes, contests, surveys and similar promotions and to administer these activities. Some of these activities may have additional rules containing information about how we use and disclose your Personal Information. Please read those rules carefully.
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, improving or modifying our Services, identifying usage trends, determining the effectiveness of promotional campaigns, and operating and expanding business activities, and similar purposes.

Disclosure of Personal Information
Your Personal Information may be disclosed:

• To our affiliates for the purposes described in this Privacy Policy.
• To our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and other similar services.
• To third-party sponsors and fulfillment vendors of sweepstakes, contests, surveys and similar promotions.
• To your friends associated with your social media account, to other website users and as well as to your social media account provider, in connection with your social sharing activity. By connecting your Site account and your social media account you authorize us to share information with your social media account provider and you understand that the use of the information we share will be governed by the social media site’s privacy policy. If you do not want your Personal Information shared with other users or with your social media account provider, please do not connect your social media account with your Site account and do not participate in social sharing on the Sites.
• To third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law and respond to requests from public and government authorities; (b) to enforce our terms and conditions; and (c) to protect and/or defend our rights, privacy, safety or property, and/or that of our affiliates, you, or others.

Online Activity Information
“Online Activity Information” means the following:

• Device Identifiers
• Cookies
• Beacons
• Pixel tags
• Mobile ad identifiers and similar technology
• Other forms of persistent or probabilistic identifiers
• Internet Protocol address
• Browsing and search history
• Other information regarding your interaction with websites, applications or advertisements

Collection of Online Activity Information
We and our service providers may collect Online Activity Information:

• Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Sites you are using. We use this information to help ensure that the Sites function properly.
• Using cookies: Cookies are pieces of information stored directly on the device that you are using. Cookies allow us to collect information such as browser type, time spent on the Sites, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security purposes, to facilitate navigation, display information more effectively, and to personalize your experience while using the Sites, as well as for online tracking purposes. We can recognize your computer to enhance your use of the Sites. We also gather statistical information about the usage of the Sites in order to periodically improve the design and functionality, understand how the Sites are used and to assist us with resolving questions regarding the Sites. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Sites. We may also use cookies in online advertising to track responses to our advertisements and we may use cookies or other files to track your use of other websites. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. However, if you do not accept these cookies, you may experience some inconvenience in your use of the Sites. For example, we may not be able to recognize your computer and you may need to log in every time you visit the Sites. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
• Analytics: We may use analytics services, which rely on cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  These services may also collect information regarding the use of other websites, apps and online resources.
• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Sites (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Sites and response rates.
• Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies: We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Sites. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Site Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Sites or our online content.
• IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our server log files whenever a user accesses the Sites, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We collect and use IP Addresses for purposes such as calculating usage levels of the Sites, helping diagnose server problems, and administering the Sites.

Other Information
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. Other Information we may collect includes:

• Demographic information and other information provided by you that does not reveal your specific identity
• Aggregated information

Please note that we may use and disclose Other Information for any purpose.

Collection of Other Information

• From you: Information such as your state of residence and your preferred means of communication is collected when you voluntarily provide this information.
• By aggregating information: We may aggregate Personal Information and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated information like general user statistics with prospective service providers. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

Third Party Advertisers
We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites, based on information relating to your access to and use of the Services and other websites. To do so, these companies may place or recognize a unique cookie on your browser (including through use of pixel tags). If you would like more information about this practice and to learn about your choices in connection with these practices, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/.

Third Party Services
This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site, social media platform or service to which the Services link. Please review any third-party privacy policies to learn how they handle your Personal Information. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

Security
We use reasonable organizational, technical and administrative measures designed to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

Choices and Access
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing-related emails by using the opt-out mechanism contained in each such email.

If you would like to update Personal Information that you have provided to us, you may contact us in accordance with the “Contacting Us” section below.

Use of Services by Minors
The Services are not directed to individuals under the age of twenty-one (21). We do not knowingly collect Personal Information from individuals under 21, and we request that individuals under 21 do not use or access the Services and that they do not provide Personal Information through the Services.

Jurisdictional Issues
The Services are controlled and operated by us from the United States, and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.

California Consumer Privacy Act (CCPA) Privacy Notice

Last Updated: September 21, 2020

Fliplop Wines has prepared this California Consumer Privacy Act (“CCPA”) Privacy Notice (the “Notice”) to inform California residents of (1) the information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household (“Personal Information”) that we collect and how we use and disclose that information, and (2) the privacy rights California residents may have relating to their Personal Information and how those rights can be exercised.

This Notice is incorporated into and forms part of our Privacy Policy. By accessing or using the Service, you agree to the practices described in this Notice. If you do not agree to this Notice, please do not access the Site or otherwise use the Services.

Personal Information Collection and Disclosure
The following tables below are intended to provide additional information about our collection and disclosure of Personal Information which we may have collected from you within the past 12 months. Nothing in this Notice limits our ability to use or disclose information as described in our Privacy Policy.

Personal Information Collected From Customers and Site Visitors

Additionally, we may disclose each of the above categories of Personal Information for Customers, Site Visitors and Applicants for Employment:

• To third parties in the event of a merger, acquisition, sale or other business combination or divestiture.
• To service providers, such as attorneys, accountants, etc. in order for them to provide services on our behalf
• To third parties and government entities, including law enforcement, as necessary for our compliance with our legal obligations or to protect our rights or the health and safety of our employees or the public.

Your rights under the CCPA
Where provided for by law and subject to any applicable exceptions and exclusions, California residents may have the following rights:

• You have the right to know:
  • what categories and specific pieces of Personal Information we have collected about you;
  • the categories of sources from which Personal Information are collected;
  • our business or commercial purpose for collecting, using, or disclosing Personal Information;
  • the categories of third parties with whom we share Personal Information; and
  • the categories of Personal Information we have sold or disclosed for a business purpose.
• You have a right to request, no more than twice in a 12-month period, that we disclose to you the specific Personal Information we have collected about you during the past 12 months.
• You have the right to opt-out of the “sale” of your Personal Information. The Wine Group does not make your Personal Information available for purchase or otherwise share your information in exchange for monetary compensation. Certain sharing of your information, however, may be considered a “sale” under the CCPA’s broad definition. In particular, in the last 12 months, if you have visited the Sites, we may have shared your Identification Information and Online Activity Information with advertising service providers and social media platforms to match and serve our targeted advertisements on third-party websites. (You can find additional information about how you can control and delete cookies here.)
• You have a right to request deletion of your personal information.
• We will not discriminate against you based on your exercise of your CCPA rights.

How can a consumer with a disability access this Notice?
Consumers who have a visual disability may be able to use a screen reader or other text-to-speech or text-to-Braille tool to review the contents of this Notice.

How to Submit a Request
To submit a request, click here or call our toll-free phone number 1-844-524-4386.

Verifying Requests
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your Personal Information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign into your account. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may require you to provide additional Personal Information for verification and, in certain circumstances, sign a declaration under penalty of perjury that you are the consumer whose Personal Information is the subject of the request. If we cannot verify your identity, we will not provide or delete your Personal Information.

Authorized Agents
You may submit a request through an authorized agent using the same methods available to you. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent signed permission to do so, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above), and confirm that you have provided the agent permission to submit the request.

Additional Information
Employees and contractors are provided notice via different statements.

Contacting Us
If you have questions or concerns regarding this Notice or the practices described, please email us at privacy@flipflopwines.com or call our toll-free phone number 1-844-524-4386.

Updates to this Privacy Policy
We may change this Privacy Policy from time to time without notice. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Sites. Your use of the Services following these changes means that you accept the revised Privacy Policy.

Contacting Us
If you have any questions about this Privacy Policy, please contact us at PrivacyPolicy@TheWineGroup.com.

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